pc
nid 93431
Jun 19, 2026
pdonofrio@vixio.com
US Track 2
American Bankers Association
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1966 charsOffice of the Comptroller of the Currency Proposes Bank Secrecy Act and Sanctions Requirements for Stablecoin Issuers
On June 22, 2026, the Office of the Comptroller of the Currency (OCC) proposed regulations to implement Bank Secrecy Act and sanctions requirements for payment stablecoin issuers. The OCC issued the rulemaking in coordination with the Financial Crimes Enforcement Network (FinCEN) and the Office of Foreign Assets Control (OFAC).
The Genius Act directs federal banking agencies to implement regulations for stablecoin issuers, with the OCC serving as the primary regulator of nonbank issuers. The Federal Deposit Insurance Corporation (FDIC) previously proposed its own anti-money laundering and counter-terrorism financing (AML/CTF) and sanctions requirements for bank subsidiaries and other financial institutions under its jurisdiction. The OCC's proposed rule requires issuers regulated by the agency to maintain effective AML/CTF and sanctions compliance programs in accordance with rules proposed by FinCEN and OFAC earlier in 2026. The proposal includes a requirement for the OCC to consult with FinCEN before taking AML/CTF enforcement actions or significant supervisory actions against issuers. It also provides issuers that establish effective AML/CFT programs with a safe harbour against certain civil enforcement and significant supervisory actions, mirroring provisions in the OCC's April AML/CTF program rule proposal for banks.
The American Bankers Association (ABA) previously raised concerns about the FinCEN and OFAC framework that the OCC plans to adopt. The ABA said any AML/CTF and sanctions rulemaking must also cover secondary market payment stablecoin activities, such as individuals purchasing payment stablecoins from an intermediary. The ABA stated that without greater clarity around the obligations of secondary market actors, regulated financial institutions will face challenges in assessing and managing risks associated with payment stablecoins.
The comment period and effective date for the proposed rule have not been announced.
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1526 charsRhode Island General Assembly Enacts HB 7265: Special Deposits Act
On June 19, 2026, the Rhode Island General Assembly enacted HB 7265 , which establishes the Rhode Island Special Deposits Act to create a uniform legal framework for the creation, management and regulation of special deposits, commonly known as escrow accounts.
The law applies to any special deposit governed by an account agreement between a bank and a depositor, or its beneficiary, that indicates an intention to be subject to the law.
Regarding the obligations and liabilities of financial institutions, the law stipulates that:
Banks do not hold a fiduciary duty regarding special deposits and instead maintain a debtor-creditor relationship when obligated to pay a beneficiary.
Banks’ liability is limited to direct damages caused by non-compliance with the account agreement, allowing them to rely on records presented in good faith.
Special deposits terminate five years after funding unless the account agreement states otherwise, with remaining balances returning to the depositor if beneficiaries cannot be identified or located.
Additionally, the law clarifies that it does not require individuals, such as landlords holding security deposits, to place funds in these accounts, but simply facilitates their use as a protective financial tool for the general public.
The law also maintains existing legal standards by providing that state law regarding consumer protection, contracts and abandoned property continue to supplement it, except where explicitly inconsistent.
The law takes effect immediately .